Provision record
BeReal · BeReal Privacy Policy · View original document ↗

International Data Transfers via Standard Contractual Clauses

Medium severity Common · 287 of 352 platforms
Stay ahead of the changes
Track BeReal and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

BeReal is a French company but may transfer your personal data to countries outside the EU/EEA, including to the United States, using Standard Contractual Clauses as the legal safeguard.

This analysis describes what BeReal's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The clause establishes the operational framework by which BeReal may process and store user personal data across international borders while maintaining compliance with EU data protection requirements. The reliance on SCCs creates enforceable contractual obligations between data processors and recipients in third countries regarding data handling standards.

Recent Activity

This document changed recently

Medium Jul 8, 2026

The updated policy now requires email address in addition to phone number, full name, and date of birth to create an account. BeReal discloses that it derives likely gender from your username, first name, and biography using AI, and uses this classification for internal targeting purposes. The policy also reveals that a randomized sample of 0.001% of users will have their interface interactions (touches and swipes) recorded through an analytics partner for up to 90 days to understand how users navigate the app; this practice does not apply in all geographic regions. You can review your app settings or contact BeReal to inquire about your data collection status.

View change record →

Clause Stability Stable

0
Changes
5
Months Monitored
Apr 3, 2026
First Seen
Apr 17, 2026
Last Seen
This clause type exists across 4430 other provisions on other platforms.

Consumer impact (what this means for users)

EU and UK users' personal data may be transferred to and processed in the United States or other third countries, which could expose it to different legal standards and government access rules.

How other platforms handle this

Skillshare Medium

Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...

Adobe Medium

we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...

Tinder Medium

we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
The personal data is transferred to countries recognized as offering an equivalent level of protection or, One of the mechanisms offering appropriate guarantees is implemented (for example, the adoption of the standard contractual clauses of the European Commission.

Excerpt from BeReal's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

Cross-border transfers must comply with GDPR Chapter V; the reliance on SCCs post-Schrems II requires a documented Transfer Impact Assessment (TIA) — compliance teams should verify BeReal has conducted TIAs for all recipient jurisdictions, particularly …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
BeReal Privacy Policy
Entity
BeReal
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-001311
Document ID
CA-D-00250
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
4d935d53ed9663cf96d1775f96c271d89ff3f9a37557b2797d6e4eee6f1993b2
Analysis generated
March 20, 2026 06:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: BeReal
Document: BeReal Privacy Policy
Record ID: CA-P-001311
Captured: 2026-03-20 06:48:38 UTC
SHA-256: 4d935d53ed9663cf…
URL: https://conductatlas.com/platform/bereal/bereal-privacy-policy/provision/CA-P-001311/international-data-transfers-via-standard-contractual-clauses/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Related Analysis

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does BeReal's International Data Transfers via Standard Contractual Clauses clause do?

The clause establishes the operational framework by which BeReal may process and store user personal data across international borders while maintaining compliance with EU data protection requirements. The reliance on SCCs creates enforceable contractual obligations between data processors and recipients in third countries regarding data handling standards.

How does this clause affect you?

EU and UK users' personal data may be transferred to and processed in the United States or other third countries, which could expose it to different legal standards and government access rules.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.

Is ConductAtlas affiliated with BeReal?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by BeReal.